State v. Hanif, 228 N.C. App. 207 (Jul. 2, 2013)

In a counterfeit controlled substance case, the trial court committed plain error by admitting evidence identifying a substance as tramadol hydrochloride based solely upon an expert’s visual inspection. The State’s witness Brian King, a forensic chemist with the State Crime Lab, testified that after a visual inspection, he identified the pills as tramadol hydrochloride. Specifically he compared the tablets’ markings to a Micromedex online database. King performed no chemical analysis of the pills. Finding that State v. Ward, 364 N.C. 133 (2010), controlled, the court held that in the absence of a scientific, chemical analysis of the substance, King’s visual inspection was insufficient to identify the composition of the pills.